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41. DOL Info. Ltr. 09-07-2022 — Information letter discussing the SECURE Act amendments to ERISA relating to the bonding requirements under ERISA section 412 that apply to pooled employer pla…
    ERISADOL Information Letters
    …l sanctions under Title I of ERISA and criminal sanctions under 18 U.S.C. 664. See U.S. v. Grizzle, 933 F.2d 943 (11th Cir. 1991), cert. denied, 502 U.S. 897 (1991).
42. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    cts and circumstances, it is inequitable to hold the individual liable for any unpaid tax or any deficiency (or any portion of either) attributable to any item for which relief is not available under the preceding sentence, the Secretary may relieve such individual of such liability. . Petitioner's request for relief r…
43. 91 FR 27140 — Excepted Fertility Benefits
    IRCProposed Rules (FR)Proposed May 13, 2026
    …76 210,739 Fully insured (States without Requirements) 314,761 229,775 84,985 165,256 Total Private 933,803 681,677 252,127 490,266 All Plans 995,792 726,928 268,864 522,811 * Totals displayed in the table may not sum due to rounding. 1  Estimated from the KFF
44. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    ugh Nov. 23,1970, and was adjusted to $81,473 in the statutory notice. Petitioner has agreed to such adjustment. SEC. 162. TRADE OR BUSINESS EXPENSES. (a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or busi…
45. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…
46. 29 C.F.R. § 2570.116 — Scope of discovery.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
47. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006
    … prior to instituting the suit was insufficient to invoke jurisdiction. Rocovich v. United States , 933 F.2d 991 (Fed. Cir. 1991); Abruzzo v. United States , 24 Cl. Ct. 668 (1991). The Internal Revenue Service Restructuring and Reform Act of 1998 enacted section 7422(j), thereby creating an exception to the “full payme…
48. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    to willful neglect . See Higbee v . Commissioner , supra at 446-447 (stating that the taxpayer bears the burden of proof regarding reasonable cause) . Accordingly, on this issue we sustain respondent's determination . V . Section 6673(a)(1 ) Section 6673(a)(1) authorizes this Court to penalize up to $25,000 a taxpayer …
49. U.S. Tax Court — Michael K. Billups v. Commissioner
    IRCCourt RulingsJun 1, 2009related by meaning
    account of the employee's disability ; (4) as part of a serie s e for life ; (5) to a employee after separation from service after attainment of ag A substantially equal periodic payments m 55 ; (6) as dividends paid with, respect to corporate stoc k described in section 404(k) ; (7) to an employee for medica l or (8)…
50. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    exceptions contained therein. See Recklitis v. Commissioner , 91 T.C. 874, 913 (1988); Tillman v. Commissioner , T.C. Memo. 1996-8. Because petitioner has not shown that any one of the exceptions applies, we sustain respondent's determination on this issue. IV. Section 6673--Penalty Awarded by Court We decide sua spont…
51. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007related by meaning
    2 Announcement 2007-52 A list is provided of organizations now classified as private foundations. ADMINISTRATIVE Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
52. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
53. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010related by meaning
    .a distribution of $6,277 from a qualified retirement . plan during~the'2001 tax year and that .she was under the age of 59-l/2 , at "the time of the distribution . . At trial Ms . O'Boyle presented no evidence that she qualified for any of the . exceptions in section 72(t)(2) . Accordingly ; we hold that Ms .-O'Boyle…
54. T.C. Memo. 2000-78 — Philip Lewis Hart v. Commissioner
    IRCCourt RulingsMar 7, 2000
    …ibution from an individual retirement account (IRA) held by National Financial Services Co., and $8,933 as a distribution from an IRA held by
55. Court of Appeals for the Seventh Circuit — Central States, SE and SW Areas Pension Fund v. Consumers Concrete Corp.
    ERISACourt RulingsSep 17, 2026
    …s a useful guide”) (citing Scalia & Garner, supra , at 141; United States v. Balint , 201 F.3d 928, 933 (7th Cir. 2000) (“[T]he Supreme Court does not consider grammar a mere technicality. It has stated that ‘Congress’ use of a verb tense is significant in construing statutes.’”) (quoting United States v. Wilson , 503 U…
56. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
57. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …ased on our own examination of the evidence in the record. Silverman v. Commissioner, 538 F.2d 927, 933 (2d Cir. 1976), aff'a T.C. Memo. 1974-285. - 25 - [*25] Combining two of the tables .s_upra, we can summarize respondent's expert's findings as to the adequacy of Dr. F1 tcher's and Ms. Fletcher's compensation: Ms. M…
58. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    me day respondent issued to petitioner a notice and demand for payment of the unpaid interest . On or about July 25, 2000, petitioner filed Form 8857, Request for Innocent Spouse Relief (And Separation of Liability and Equitable Relief ), requesting section 6015 ( f) equitable relief from the unpaid interest . More tha…
59. 38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
    IRCCourt RulingsSep 21, 1962related by meaning
    because in the opinion of the Canadian counsel, petitioner had no claim recognizable under Canadian law and to proceed with the suit would be costly. In July 1958 petitioner, through its counsel, engaged a French attorney to attempt to recover, through the liquidator of SNAB in France. Later in 1958 the French attorne…
60. T.C. Memo. 2007-327 — Gregory Eugene Thompson v. Commissioner
    IRCCourt RulingsOct 31, 2007related by meaning
    ner's legal obligations here . See, e .g ., Pessin v . Commissioner , 59 T .C . 473, 489 (1972) ; Rosanova v . Commissioner , T .C . Memo . 1985-306 ; Grant v . Commissioner , T .C . Memo . 1980-242 . -11IV . Section 6673 Penalt y We now consider whether petitioner should be held liable for a penalty under section 6673…